What is CIT v. SFIL Stock Broking Ltd. authority for?

Reassessment proceedings under Section 147 are invalid and void ab initio if initiated based on 'borrowed satisfaction' without the Assessing Officer's independent application of mind, or merely on documents already available on record without fresh tangible material.

How many judgments cite CIT v. SFIL Stock Broking Ltd.?

243 judgments on BharatTax cite CIT v. SFIL Stock Broking Ltd. (325 ITR 285), spanning 2011 to 2026.

Which sections of the Income Tax Act does CIT v. SFIL Stock Broking Ltd. come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 68, Section 250, Section 151.

CIT v. SFIL Stock Broking Ltd. (325 ITR 285)

DCIT, Circle-12(1), Kolkata vs. M/S Dotex Merchandise Pvt. Ltd., Kolkata

In the result, appeal of the Revenue is dismissed and the cross objections are also dismissed as infructuous

ITA 1602/KOL/2016[2010-11]Status: DisposedITAT Kolkata03 May 2019AY 2010-11

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 133(6)Section 142(1)Section 143(1)Section 147Section 148Section 68

…CIT Vs. Shodiman Investments (P) Ltd., 93 taxmann.com 153 (Bom) - CIT VsParamjitKaur, 168 Taxman 39 (P&H HC) - Pr.CITVs RMG Polyvinyl (I) Ltd, 83 taxmann.com 348 (Del HC) - CIT VsInsceticides (India) Ltd, 357 ITR 330 (Del HC) - CIT Vs SFIL Stock Broking Ltd., 325 ITR 285 (Del HC) 11. We have heard rival submissions and gone through the facts and circumstances of the case. From the foregoing facts and applicable legal provisions the short question which needs to be adjudicated in the present appeal is whether the assessment order u/s 147 passed 12 ITA No. 1602/Kol/2016 & CO No. 55 of 2016 Dotex Merchandise Pvt.…

Kamal Kishoree Aggarwal, New Delhi vs. ACIT, Circle- 34(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 6628/DEL/2018[2009-10]Status: DisposedITAT Delhi12 Apr 2019AY 2009-10

Bench: Sh. N. S. Sainiita No. 6628/Del/2018 : Asstt. Year : 2009-10 Kamal Kishoree Aggarwal, Vs Acit, A-57, Ashok Vihar, Phase-I, Circle-34(1), New Delhi-110052 New Delhi (Appellant) (Respondent) Pan No. Ackpa3670L Assessee By : Sh. Pancham Sethi, Fca Revenue By : Sh. S. L. Anuragi, Sr. Dr Date Of Hearing: 11.04.2019 Date Of Pronouncement: 12.04.2019 Order This Is An Appeal Filed By The Assessee Against The Order Of Cit(A)-12, New Delhi Dated 13.07.2018. 2. The Assessee Has Raised Following Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case, The Order Passed U/S 250(6) By The Ld. Cit(A) Confirming The Assessment Order Passed U/S 143(3) R.W.S. 147 By The Ld. Assessing Officer Is Bad In Law. 2. The Ld. Cit(A) Has Erred Both In Law & On The Facts Of The Case By Upholding The Action Of The Ld. Assessing Officer To Initiate Reopening & Reassessment Of The Case U/S 147 Of The Income Tax Act 1961. 3. Ld. Cit(A) Has Erred In Confirming The Addition Of Rs. 5,96,177/- Made By Ld. Ao U/S 143(3) R.W.S. 147 By Treating Certain Share Transactions As Bogus. 4. Ld. Cit(A) Has Erred In Not Recognizing The Fact That The Client Code Modification (Ccm) Was Done To Rectify The Genuine Errors Held At The End Of Broker For Which The Assessee Was Not Responsible. 2 Kamal Kishoree Aggarwal 5. Ld. Cit(A) Has Erred In Confirming The Order Of Ld. Ao Even When The Ld. Ao Failed To Provide The Details Of The Transactions Where Client Code Was Modified. 6. Ld. Assessing Officer Has Erred Both In Law & On Facts Of The Case In Initiating Penalty Proceedings U/S 271(1)(C) Read With Section 274 Of The It Act, 1961. 7. The Appellant Craves Leave To Amend, Delete Or Add Any Grounds Of Appeal Before Or During The Course Of Hearing Of The Appeal.” 3. In Ground Nos. 1 & 2 Of The Appeal, The Assessee Has Challenged The Reopening Of Assessment Made U/S 147 Of The Act Is Bad In Law.

For Appellant: Sh. Pancham Sethi, FCAFor Respondent: Sh. S. L. Anuragi, Sr. DR

Section 143(3)Section 147Section 148Section 250(6)Section 271(1)(c)Section 274

…on of mind is not valid.- " Commissioner of Income-tax v. Smt. Paramjit Kaur [(2008) 168 Taxman 39 (P&H)]: " Sarthak Securities Co. Pvt. Ltd. v. Income Tax Officer [(2010) 195 Taxman 262 (Delhi)]: " Commissioner of Income-tax v SFIL Stock Broking Ltd. [(2010) 325 ITR 285 (Delhi)]: 6 Kamal Kishoree Aggarwal (11) The above view has also been recently affirmed by the Delhi High Court in the case of Pr. Commissioner of Income-tax v. G & G Pharma India Ltd [(2016) 384 ITR I47 (Delhi)] which their Lordships have dearly held that "prior to the reopening of the assessment, the AO has to. applying his mind to the materia…

Laxmipat Dudheria, Bangalore vs. Assistant Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, all the four appeals filed by the assessee are allowed

ITA 2376/BANG/2018[2015-16]Status: DisposedITAT Bangalore08 Apr 2019AY 2015-16

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &

Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

…) ITO & Ors vs. LakhmaniMewalDas, 103 ITR 437 (SC). b) PCIT Vs. Meenakshi Overseas Pvt Ltd, DEL HC-395 ITR 677 c) CIT Vs. Valvoline Cummins Ltd, Del HC-90 CCH 233 d) Bakulbhai Ramanlal Patel Vs. ITO, GUJ HC-56 DTR 212 e) CIT vs. SFIL Stock Broking Ltd, Del HC-325 ITR 285 f) Devansh Exports vs. ACIT, Kolkata ITAT-54 CCH 85 25. As per Para 11 of the judgment of Hon’ble apex court rendered in the case of ITO vs. Lakhmani Mewal Das (Supra), it was held that the reasons for the formation of the belief must have rational connection with or relevant bearing on the formation of belief. For ready reference, this para of t…

Laxmipat Dudheria, Bangalore vs. Assistant Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, all the four appeals filed by the assessee are allowed

ITA 2375/BANG/2018[2014-15]Status: DisposedITAT Bangalore08 Apr 2019AY 2014-15

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &

Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

…) ITO & Ors vs. LakhmaniMewalDas, 103 ITR 437 (SC). b) PCIT Vs. Meenakshi Overseas Pvt Ltd, DEL HC-395 ITR 677 c) CIT Vs. Valvoline Cummins Ltd, Del HC-90 CCH 233 d) Bakulbhai Ramanlal Patel Vs. ITO, GUJ HC-56 DTR 212 e) CIT vs. SFIL Stock Broking Ltd, Del HC-325 ITR 285 f) Devansh Exports vs. ACIT, Kolkata ITAT-54 CCH 85 25. As per Para 11 of the judgment of Hon’ble apex court rendered in the case of ITO vs. Lakhmani Mewal Das (Supra), it was held that the reasons for the formation of the belief must have rational connection with or relevant bearing on the formation of belief. For ready reference, this para of t…

Laxmipat Dudheria, Bangalore vs. Assistant Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, all the four appeals filed by the assessee are allowed

ITA 2374/BANG/2018[2013-14]Status: DisposedITAT Bangalore08 Apr 2019AY 2013-14

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &

Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

…) ITO & Ors vs. LakhmaniMewalDas, 103 ITR 437 (SC). b) PCIT Vs. Meenakshi Overseas Pvt Ltd, DEL HC-395 ITR 677 c) CIT Vs. Valvoline Cummins Ltd, Del HC-90 CCH 233 d) Bakulbhai Ramanlal Patel Vs. ITO, GUJ HC-56 DTR 212 e) CIT vs. SFIL Stock Broking Ltd, Del HC-325 ITR 285 f) Devansh Exports vs. ACIT, Kolkata ITAT-54 CCH 85 25. As per Para 11 of the judgment of Hon’ble apex court rendered in the case of ITO vs. Lakhmani Mewal Das (Supra), it was held that the reasons for the formation of the belief must have rational connection with or relevant bearing on the formation of belief. For ready reference, this para of t…

Laxmipat Dudheria, Bangalore vs. Assistant Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, all the four appeals filed by the assessee are allowed

ITA 2373/BANG/2018[2012-13]Status: DisposedITAT Bangalore08 Apr 2019AY 2012-13

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &

Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

…) ITO & Ors vs. LakhmaniMewalDas, 103 ITR 437 (SC). b) PCIT Vs. Meenakshi Overseas Pvt Ltd, DEL HC-395 ITR 677 c) CIT Vs. Valvoline Cummins Ltd, Del HC-90 CCH 233 d) Bakulbhai Ramanlal Patel Vs. ITO, GUJ HC-56 DTR 212 e) CIT vs. SFIL Stock Broking Ltd, Del HC-325 ITR 285 f) Devansh Exports vs. ACIT, Kolkata ITAT-54 CCH 85 25. As per Para 11 of the judgment of Hon’ble apex court rendered in the case of ITO vs. Lakhmani Mewal Das (Supra), it was held that the reasons for the formation of the belief must have rational connection with or relevant bearing on the formation of belief. For ready reference, this para of t…

Smt. Vidhya Agarwal, Agra vs. I.T.O., Ward-4(4), Agra

The appeal is allowed

ITA 335/AGR/2014[2000-01]Status: DisposedITAT Agra22 Mar 2019AY 2000-01

Bench: Shri Sudhanshu Srivastava & Dr. Mitha Lal Meena

Section 148

…to the Appellant to 31 I.T.A No. 216 /Agra/2012 & Others challenge the reasons recorded under section 148(2) on the ground that, they do not meet the standards set in the various judicial pronouncements. " 13. In the case of CIT Vs. SFIL Stock Broking Ltd.', 325 ITR 285 (Del), the Hon'ble Delhi High Court also had the occasion to consider the applicability of the Judgment delivered in `Rajesh Jhaveri' (supra). The Hon'ble High Court, while holding in favour of the assessee, observed as under: "8. After having heard the counsel for the parties, we are inclined to agree with the submissions made by the respondent…

ITO, New Delhi vs. M/S. Jai Gajanan Enterprises Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 4861/DEL/2015[2007-08]Status: DisposedITAT Delhi15 Mar 2019AY 2007-08

Bench: : Shri Amit Shukla & Shri L.P. Sahuassessment Year: 2007-08

Section 132Section 143(3)Section 147Section 148Section 271(1)(c)Section 68

…tainable. Reliance on this point is placed on the following decisions :- • Sarthak Securities Co. (P.) Ltd v. ITO [2010] 195 Taxman 262 (Delhi); • Signature Hotels (P.) Ltd. v. ITO [2012] 20 taxmann.com 797 (Delhi); • CIT v. Sfil Stock Broking Ltd. [2010] 325 ITR 285 (Delhi); • CIT v. Suren International (P.) Ltd. [2013] 35 taxmann.com 398 (Delhi); • Italica Floor Tiles Pvt. Ltd. and others v. ACIT 2015 (6) TMI 382 - ITAT RAJKOT 4.3 It has been next contended on validity of reopening of assessment has been that Proviso to Section 147 is not satisfied. The original assessment was done u/s 143(3). The factum…

M/S Holy Faith International Pvt. Ltd, Jalandhar vs. The Dy Commissioner of Income Tax, Jalandhar

In the result, the appeal of the assessee is allowed

ITA 181/ASR/2017[2008-09]Status: DisposedITAT Amritsar15 Jan 2019AY 2008-09

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.181/Asr./2017 : Asstt. Year : 2008-09 M/S Holy Faith International Vs Deputy Commissioner Of Income Tax, Pvt. Ltd., Mbd House, Central Circle-Ii, Railway Road, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Aaach6111J Assessee By : Sh. Sudhir Sehgal, Adv. Revenue By : Sh. Bhawani Shankar, Dr Date Of Hearing : 07.01.2019 Date Of Pronouncement : 15.01.2019 Order Per N. K. Saini: This Is An Appeal By The Assessee Against The Order Dated 20.03.2017 Of Ld. Cit(A)-I, Jalandhar. 2. Following Grounds Have Been Raised In This Appeal: “1. That The Worthy Commissioner Of Income Tax (A)-1, Jalandhar Has Erred In Dismissing The Appeal Filed By The Assessee. 2. That The Ld. Cit(A) Has Erred In Confirming The Contention Of The Assessing Officer In Reopening The Case U/S 148 Of The Income Tax Act And, Thus, Framing Of Assessment U/S 147 R.W.S.143(3)/153C At An Income Of Rs. 4,95,13,441/- Against The Returned Income Of Rs. 4,63,33,441/-. 3. That The Ld. Cit(A) Has Erred In Not Considering That There Was No Reason To Believe That The Income Of The

For Appellant: Sh. Sudhir Sehgal, AdvFor Respondent: Sh. Bhawani Shankar, DR

Section 131Section 132Section 147Section 148Section 153C

…AO only on the basis of information received from the Directorate of Income Tax without making an inquiry was not justified. The reliance was placed on the following case laws: " Sheo Nath Singh Vs ACIT 82 ITR 0147 (SC) " CIT Vs SFIL Stock Broking Ltd. (2010) 325 ITR 285 (Del.) " Pr. CIT Vs G. G. Pharma India Ltd. 384 ITR 147 (Del.) " Signature Hotels Pvt. Ltd. Vs ITO 338 ITR 51 (Del.) " ITO Vs Narnaudia Financial Services Pvt. Ltd. in ITA No. 4094/Del/2009 " Sh. Chunnilal Prajapati Vs ITO-II in ITA Nos.290 to 295/Luc/2010 " G. N. Shaw (Wine) (P) Ltd. Vs ITO 260 ITR 513 (Cal.) " Sun Pharmaceutical Industries Ltd.…

Bhopal Singh Shekhawat, Jaipur vs. ITO, Jaipur

ITA 656/JPR/2016[2008-09]Status: DisposedITAT Jaipur11 Jan 2019AY 2008-09

For Appellant: Shri Mahendra Gargieya (Adv)For Respondent: Shri J.C. Kulhari (JCIT)

Section 143(1)Section 147Section 148Section 234ASection 244ASection 251Section 45Section 48(2)

…ntion, he has relied upon the decision of the Hon’ble Jurisdictional High Court in the case of CIT Vs. Shri Rajasthan Syntax Ltd. (2009) 313 ITR 231 (Raj) as well as the decision of the Hon’ble Delhi High Court in the case of CIT Vs. SFIL Broking Ltd. (2010) 325 ITR 285 (Del). 4. On the other hand, the ld DR has submitted that the assessee has not disclosed any capital gain in his return of income and subsequently the Assessing Officer received information that the assessee has sold as many as four properties during the year under consideration, therefore, ITA 656/JP/2016_ 6 Bhopal Singh Shekhawat Vs ITO the…

M/S. Proficient Commodities Pvt. Ltd., Kolkata vs. DCIT, Circle - 5(1), Kolkata

In the result, both these appeals of the assessee are allowed

ITA 2308/KOL/2017[2011-12]Status: DisposedITAT Kolkata02 Nov 2018AY 2011-12

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi]

Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘D’ BENCH, KOLKATA [Before Sri J. Sudhakar Reddy, Accountant Member & Sri S.S. Viswanethra Ravi, Judicial Member] I.T.A. No. 2307/Kol/2017 Assessment Year: 2010-11 I.T.A. No.2308/Kol/2017 Assessment Year: 2011-12 Proficient Commodities Pvt. Ltd.....………………………………………………….…….……………..Appellant C/o. S.N Ghosh & Associates, Advocates ‘Seben Brothers’ Lodge’ P.O. Buroshibtala P.S. Chinsurah Dist. Hooghly PIN-712 105 [PAN : AADCP 7843 A] D.C.I.T., Circle-5(1), Kolkata..........................................................……………………………...Respondent Appearances by: Shri Som…

M/S. Proficient Commodities Pvt. Ltd., Kolkata vs. DCIT, Circle - 5(1), Kolkata

In the result, both these appeals of the assessee are allowed

ITA 2307/KOL/2017[2010-11]Status: DisposedITAT Kolkata02 Nov 2018AY 2010-11

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi]

Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘D’ BENCH, KOLKATA [Before Sri J. Sudhakar Reddy, Accountant Member & Sri S.S. Viswanethra Ravi, Judicial Member] I.T.A. No. 2307/Kol/2017 Assessment Year: 2010-11 I.T.A. No.2308/Kol/2017 Assessment Year: 2011-12 Proficient Commodities Pvt. Ltd.....………………………………………………….…….……………..Appellant C/o. S.N Ghosh & Associates, Advocates ‘Seben Brothers’ Lodge’ P.O. Buroshibtala P.S. Chinsurah Dist. Hooghly PIN-712 105 [PAN : AADCP 7843 A] D.C.I.T., Circle-5(1), Kolkata..........................................................……………………………...Respondent Appearances by: Shri Som…

DCIT, New Delhi vs. M/S. Erawat Infotech Pvt. Ltd., New Delhi

Accordingly, we set-aside the order of the Ld. CIT(A) to the extent of holding the proceedings under section 147 of the Act is invalid. The grounds of the appeal of the Revenue are accordingly allowed

ITA 5570/DEL/2011[2002-03]Status: DisposedITAT Delhi24 Oct 2018AY 2002-03

Bench: Shri Amit Shukla & Shri O.P. Kantassessment Year: 2002-03 Dcit, Vs. M/S. Erawat Infotech Pvt. Central Circle-23, Room No. Ltd., 359, E-2, Ara Centre, B-44, Second Floor, Jhandewalan Extn., New Jangpura –B, New Delhi Delhi Pan :Aaace8941P (Appellant) (Respondent)

Section 131Section 143(1)Section 147Section 148Section 68

…ve at own satisfaction for valid initiation of proceedings u/s 147, it is held that the case of the appellant is squarely covered by the decisions of the Hon’ble Jurisdictional High Court in the case of M/s. Commissioner of Income V/s SFIL Stock Broking Ltd., 325 ITR 285 (Delhi), CIT Vs. Atul Jain and Vinita Jain, 299 ITR 383 (Delhi) & Sarthak Securities Co. P. Ltd. V/s Income Tax Officer, 329 ITR 110 (Delhi) the gist of which have been provided in paras 5.6, 5.7 & 5.8 (supra).” 11. In the case of CIT Vs SFIL Stock Broking Ltd(supra) relied upon by the Ld. CIT(A), the reassessment was held invalid due to non-app…

Rajiv Jain, New Delhi vs. ITO, Ward- 63(2), New Delhi

In the result, both appeals filed by the appellant’s are allowed

ITA 7061/DEL/2017[2007-08]Status: DisposedITAT Delhi27 Sept 2018AY 2007-08

Bench: Shri N. K. Billaiya

For Appellant: Sh. Naveen Kumar Goyal, CAFor Respondent: Sh. Surender Pal, Sr. DR

Section 147Section 148Section 153A

…that SS Ltd is a non existing and a fictitious entity/person. For the 9 ITA No.-7059/Del/2017 &7061/Del/2017 reasons stated above, writ of the certiorari is issued quashing the proceedings u/s 148 of the Act.” 13. In the case of CIT Vs. SFIL Stockbroking Co. 325 ITR 285, it has been held as under” “The first sentence of the so-called reasons recorded by the Assessing Officer is mere information received from the Deputy Director of Income Tax (Investigation). The second sentence is a direction given by the very same Deputy Director of Income Tax (Investigation) to issue a notice under Section 148 and the third…

M/S. Anjli Metal Overseas Prop. Neeraj Rathore, Delhi vs. ITO, Ward- 63(3), New Delhi

In the result, both appeals filed by the appellant’s are allowed

ITA 7059/DEL/2017[2007-08]Status: DisposedITAT Delhi27 Sept 2018AY 2007-08

Bench: Shri N. K. Billaiya

For Appellant: Sh. Naveen Kumar Goyal, CAFor Respondent: Sh. Surender Pal, Sr. DR

Section 147Section 148Section 153A

…that SS Ltd is a non existing and a fictitious entity/person. For the 9 ITA No.-7059/Del/2017 &7061/Del/2017 reasons stated above, writ of the certiorari is issued quashing the proceedings u/s 148 of the Act.” 13. In the case of CIT Vs. SFIL Stockbroking Co. 325 ITR 285, it has been held as under” “The first sentence of the so-called reasons recorded by the Assessing Officer is mere information received from the Deputy Director of Income Tax (Investigation). The second sentence is a direction given by the very same Deputy Director of Income Tax (Investigation) to issue a notice under Section 148 and the third…

Ajay Sharma, Delhi vs. ITO, Ward- 35(3), New Delhi

The appeal of the assessee is allowed

ITA 2723/DEL/2018[2010-11]Status: DisposedITAT Delhi26 Sept 2018AY 2010-11

Bench: Shri N. K. Saini & Ms Suchitra Kamblejyoti Engineering Works Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, Rohini New Delhi Delhi Aadfj9259M (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Ajay Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, New Delhi Rohini, Delhi Abbps7289K (Appellant) (Respondent)

Section 148

…The facts indicated above do not show that SS Ltd is a non existing and a fictitious entity/person. For the reasons stated above, writ of the certiorari is issued quashing the proceedings u/s 148 of the Act.” 13. In the case of CIT Vs. SFIL Stockbroking Co. 325 ITR 285, it has been held as under” “The first sentence of the so-called reasons recorded by the Assessing Officer is mere information received from the Deputy Director of Income Tax (Investigation). The second sentence is a direction given by the very same Deputy Director of Income Tax (Investigation) to issue a notice under Section 148 and the third…

Ajay Sharma, Delhi vs. ITO, Ward- 35(3), New Delhi

The appeal of the assessee is allowed

ITA 2722/DEL/2018[2009-10]Status: DisposedITAT Delhi26 Sept 2018AY 2009-10

Bench: Shri N. K. Saini & Ms Suchitra Kamblejyoti Engineering Works Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, Rohini New Delhi Delhi Aadfj9259M (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Ajay Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, New Delhi Rohini, Delhi Abbps7289K (Appellant) (Respondent)

Section 148

…The facts indicated above do not show that SS Ltd is a non existing and a fictitious entity/person. For the reasons stated above, writ of the certiorari is issued quashing the proceedings u/s 148 of the Act.” 13. In the case of CIT Vs. SFIL Stockbroking Co. 325 ITR 285, it has been held as under” “The first sentence of the so-called reasons recorded by the Assessing Officer is mere information received from the Deputy Director of Income Tax (Investigation). The second sentence is a direction given by the very same Deputy Director of Income Tax (Investigation) to issue a notice under Section 148 and the third…

Sadhna Sharma, Delhi vs. ITO, Ward-35(3), New Delhi

The appeal of the assessee is allowed

ITA 2721/DEL/2018[2010-11]Status: DisposedITAT Delhi26 Sept 2018AY 2010-11

Bench: Shri N. K. Saini & Ms Suchitra Kamblejyoti Engineering Works Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, Rohini New Delhi Delhi Aadfj9259M (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Ajay Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, New Delhi Rohini, Delhi Abbps7289K (Appellant) (Respondent)

Section 148

…The facts indicated above do not show that SS Ltd is a non existing and a fictitious entity/person. For the reasons stated above, writ of the certiorari is issued quashing the proceedings u/s 148 of the Act.” 13. In the case of CIT Vs. SFIL Stockbroking Co. 325 ITR 285, it has been held as under” “The first sentence of the so-called reasons recorded by the Assessing Officer is mere information received from the Deputy Director of Income Tax (Investigation). The second sentence is a direction given by the very same Deputy Director of Income Tax (Investigation) to issue a notice under Section 148 and the third…

Sadhna Sharma, Delhi vs. ITO, Ward-35(3), New Delhi

The appeal of the assessee is allowed

ITA 2720/DEL/2018[2009-10]Status: DisposedITAT Delhi26 Sept 2018AY 2009-10

Bench: Shri N. K. Saini & Ms Suchitra Kamblejyoti Engineering Works Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, Rohini New Delhi Delhi Aadfj9259M (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Ajay Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, New Delhi Rohini, Delhi Abbps7289K (Appellant) (Respondent)

Section 148

…The facts indicated above do not show that SS Ltd is a non existing and a fictitious entity/person. For the reasons stated above, writ of the certiorari is issued quashing the proceedings u/s 148 of the Act.” 13. In the case of CIT Vs. SFIL Stockbroking Co. 325 ITR 285, it has been held as under” “The first sentence of the so-called reasons recorded by the Assessing Officer is mere information received from the Deputy Director of Income Tax (Investigation). The second sentence is a direction given by the very same Deputy Director of Income Tax (Investigation) to issue a notice under Section 148 and the third…

Jyoti Engineering Works, Delhi vs. ITO, Ward-35(3), New Delhi

The appeal of the assessee is allowed

ITA 2719/DEL/2018[2007-08]Status: DisposedITAT Delhi26 Sept 2018AY 2007-08

Bench: Shri N. K. Saini & Ms Suchitra Kamblejyoti Engineering Works Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, Rohini New Delhi Delhi Aadfj9259M (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Sadhna Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sectdor-7, New Delhi Rohini, Delhi Aawps0941G (Appellant) (Respondent) Ajay Sharma Vs Ito C/O. Kapil Goel, Advocate, F-26/124, Ward-35(3) Sector-7, New Delhi Rohini, Delhi Abbps7289K (Appellant) (Respondent)

Section 148

…The facts indicated above do not show that SS Ltd is a non existing and a fictitious entity/person. For the reasons stated above, writ of the certiorari is issued quashing the proceedings u/s 148 of the Act.” 13. In the case of CIT Vs. SFIL Stockbroking Co. 325 ITR 285, it has been held as under” “The first sentence of the so-called reasons recorded by the Assessing Officer is mere information received from the Deputy Director of Income Tax (Investigation). The second sentence is a direction given by the very same Deputy Director of Income Tax (Investigation) to issue a notice under Section 148 and the third…

CIT v. SFIL Stock Broking Ltd.

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Judgments citing CIT v. SFIL Stock Broking Ltd.

DCIT, Circle-12(1), Kolkata vs. M/S Dotex Merchandise Pvt. Ltd., Kolkata

Kamal Kishoree Aggarwal, New Delhi vs. ACIT, Circle- 34(1), New Delhi

Laxmipat Dudheria, Bangalore vs. Assistant Commissioner of Income Tax Circle-7(1)(2), Bangalore

Laxmipat Dudheria, Bangalore vs. Assistant Commissioner of Income Tax Circle-7(1)(2), Bangalore

Laxmipat Dudheria, Bangalore vs. Assistant Commissioner of Income Tax Circle-7(1)(2), Bangalore

Laxmipat Dudheria, Bangalore vs. Assistant Commissioner of Income Tax Circle-7(1)(2), Bangalore

Smt. Vidhya Agarwal, Agra vs. I.T.O., Ward-4(4), Agra

ITO, New Delhi vs. M/S. Jai Gajanan Enterprises Pvt. Ltd., New Delhi

M/S Holy Faith International Pvt. Ltd, Jalandhar vs. The Dy Commissioner of Income Tax, Jalandhar

Bhopal Singh Shekhawat, Jaipur vs. ITO, Jaipur

M/S. Proficient Commodities Pvt. Ltd., Kolkata vs. DCIT, Circle - 5(1), Kolkata

M/S. Proficient Commodities Pvt. Ltd., Kolkata vs. DCIT, Circle - 5(1), Kolkata

DCIT, New Delhi vs. M/S. Erawat Infotech Pvt. Ltd., New Delhi

Rajiv Jain, New Delhi vs. ITO, Ward- 63(2), New Delhi

M/S. Anjli Metal Overseas Prop. Neeraj Rathore, Delhi vs. ITO, Ward- 63(3), New Delhi

Ajay Sharma, Delhi vs. ITO, Ward- 35(3), New Delhi

Ajay Sharma, Delhi vs. ITO, Ward- 35(3), New Delhi

Sadhna Sharma, Delhi vs. ITO, Ward-35(3), New Delhi

Sadhna Sharma, Delhi vs. ITO, Ward-35(3), New Delhi

Jyoti Engineering Works, Delhi vs. ITO, Ward-35(3), New Delhi